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6760 W Monona Drive  Glendale, AZ 85308  Phone: 602-809-5207  UAV101@COX.NET

Lorie Grabham

September 16, 2015

U.S. Department of Transportation

Docket Management System

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., Se

Washington, DC 20590

Re: Exemption Pursuant to Section 333

Lorie Grabham respectfully requests relief from the following regulations for the purpose of 

commercial aerial flight operations. I intend to operate the DJI Phantom 2 Vision, DJI Inspire 1

and/or DJI Phantom 3 Professional quadcopter UAV in Arizona for the purpose of aerial data 

collection to produce images/video for use in aerial videography/cinematography and 

augmenting real estate listing videos (or similar operations), special events, commercial 

advertising, education, training/safety programs and products.

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR 61.113 (a) & (b), 14 CFR 91.7(a), 14 CFR 91.9 (b) (2), 14 C.F.R. 

91.103, 14 CFR 91.109, 14 C.F. R. 91.119, 14 C.F.R. 91.121, 14 CFR 91.151 (a), 14 CFR 

91.405 (a), 14 CFR 407 (a) (1) ,14 CFR 409 (a) (2), 14 CFR 417 (a) & (b)

UAS operated by Lorie Grabham weigh less than 10 pounds, including payload (i.e. camera, 

lens, gimball). They operate at speeds no more than 35 knots, capable of vertical and horizontal 

operations and will only operate in line of sight and within secure areas. The operations will 

insure that the UAS will “not create a hazard to users of the national airspace system or the 

public.” This small UAV is designed to primarily hover in place. The UAS will never be flown 

over 400 feet AGL and will never be flown directly over persons. The total UAS flight time would 

be 25 minutes or less.

A pre-flight check will always be done before every flight. The UAS will be checked for cracks, 

wire frays, propeller condition, power test, battery life, motor calibration, tablet battery life, 

connection to UAS camera and tablet.

I am finishing with my Masters in Unmanned Systems Engineering. I am the Communications 

Director of the Association for Unmanned Vehicle Systems International Saguaro Chapter. I 

believe in providing a united front to regulators and government leaders on behalf of industries, 

like myself, to use this technology and to use it responsibly. 

I will comply with the requirement to obtain a Certificate of Waver or Authorization from the FAA 

Air Traffic Organization prior to conduction in the NAS.
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6760 W Monona Drive  Glendale, AZ 85308  Phone: 602-809-5207  UAV101@COX.NET

Granting Lorie Grabham’s exemption request furthers the public interest. Granting this request 

comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities to not only 

integrate UAS’s into the National Airspace System (NAS), but to “...establish requirements for 

the safe operation of such aircraft systems in the national airspace system” under section 333(c) 

of the Reform Act. Further, Lorie Grabham will conduct its operations in compliance with the 

protocols described herein or as otherwise established by the FAA. Allowing to log flight time 

directly relates to the research and the ability to further enhance current safety measures.

Granting this request will allow small business owners and homeowners the ability to afford high 

quality aerial images and video that they would otherwise have no access to due to many 

factors.

The detail and specifics of 14 C.F.R. from which Lorie Grabham seeks exemption:

1. Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.
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6760 W Monona Drive  Glendale, AZ 85308  Phone: 602-809-5207  UAV101@COX.NET

4. Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed, to

fly after that for at least 20 minutes.

5. Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter.

7. Exemption From The Requirements Of Sections 91.409(a)(1)

And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. Exemption From The Requirements Of Sections 91.417(a)

And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and

each engine, propeller, rotor, and appliance of an aircraft. The records must

include--

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.
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6760 W Monona Drive  Glendale, AZ 85308  Phone: 602-809-5207  UAV101@COX.NET

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and

each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after the

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is

approved for return to service.

I can be reached at (602)809-5207 or UAV101@cox.net if further information is needed.

Thank you.